12-12020-mg Doc 8948 Filed 07/31/15 Entered 07/31/15 12:53:48 Main Document Pg 1 of 3 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: RESIDENTIAL CAPITAL, LLC, et al., Debtors. Case No. 12-12020 (MG) Chapter 11 Jointly Administered DECLARATION OF MATTHEW R. SCHECK I, MATTHEW R. SCHECK, declare pursuant to 28 U.S.C. 1746 as follows: 1. I am an attorney with the law firm of Quinn Emanuel Urquhart & Sullivan, LLP, counsel for the ResCap Liquidating Trust (the Trust ). I am a member in good standing of the Bars of California and New York, and admitted in this Court. I respectfully submit this declaration in support of the Motion Of The Rescap Liquidating Trust For An Order Enforcing Plan Injunction And Confirmation Order (the Motion ). 2. Prior to preparation of the Motion, I requested and obtained from the Claims and Noticing Agent, Kurtzman Carson Consultants ( KCC ), a searchable list, compiled and maintained by KCC, of proofs of claim filed in the above-captioned cases. I searched the list for Decision One Mortgage Company, LLC ( Decision One ), Honor Bank f/k/a The Honor State Bank ( Honor Bank ), and Sierra Pacific Mortgage Company, Inc. ( Sierra Pacific ), and found that none were listed as having filed a proof of claim. 3. Attached hereto as Exhibit A is a true and correct copy of Proof of Claim No. 4462, filed on November 12, 2012 by PHH Mortgage Corporation ( PHH ) against Residential Funding Company, LLC ( RFC ). Due to their voluminous nature, the exhibits to the proof of claim have been excluded, but they will be provided upon the Court s request. 1
12-12020-mg Doc 8948 Filed 07/31/15 Entered 07/31/15 12:53:48 Main Document Pg 2 of 3 4. Attached hereto as Exhibit B is a true and correct copy of Proof of Claim No. 7173, filed on September 18, 2013 by PHH against RFC. Other than Proofs of Claim 4462 and 7173, the list provided to me by KCC did not show any other proofs of claim filed by PHH. 5. Attached hereto as Exhibit C is a true and correct copy of a July 16, 2015 email I sent to counsel for Decision One. 6. Attached hereto as Exhibit D is a true and correct copy of a July 16, 2015 email I sent to counsel for PHH. 7. Attached hereto as Exhibit E is a true and correct copy of a July 17, 2015 email I sent to counsel for Honor Bank. 8. Attached hereto as Exhibit F is a true and correct copy of a July 20, 2015 email I sent to counsel for Sierra Pacific. 9. Attached hereto as Exhibit G are true and correct excerpts from the transcript of a July 23, 2015 status conference and motions hearing in In re RFC & ResCap Liquidating Trust Litigation, No. 13-cv-3451 (D. Minn.). 10. Attached as Exhibit H is a true and correct copy of a Renewal of Registration that I obtained from the Oregon Secretary of State s website. The document indicates that it was electronically filed with the Oregon Secretary of State on July 19, 2012 for Assumed Business Name 1st Choice Mortgage of Oregon, listing Sierra Pacific as Registrant, with a Mailing Address of 50 Iron Point Circle Ste. 200, Folsom, CA 95630. 11. Attached as Exhibit I is a true and correct copy of a 2012 Annual Report that Sierra Pacific filed with the Oregon Secretary of State on July 17, 2012, indicating a change of address from 50 Iron Pt Cir Ste 200, Folsom, CA 95630 to 1180 Iron Point Rd #200, Folsom, CA 95630. 2
12-12020-mg Doc 8948 Filed 07/31/15 Entered 07/31/15 12:53:48 Main Document Pg 3 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on July 31, 2015, in Los Angeles, CA. /s/ Matthew Scheck Matthew Scheck 3
12-12020-mg Doc 8948-1 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit A Pg 1 of 6 EXHIBIT A
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12-12020-mg Doc 8948-2 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit B Pg 1 of 3 EXHIBIT B
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12-12020-mg Doc 8948-3 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit C Pg 1 of 2 EXHIBIT C
12-12020-mg Doc 8948-3 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit C Pg 2 of 2 Matthew Scheck From: Sent: To: Cc: Subject: Matthew Scheck Thursday, July 16, 2015 11:35 AM Ahmad, N. Mahmood; Johnson, Matthew; Joseph, Cheryl Isaac Nesser Decision One Counterclaim Counsel, Further to our conversation this morning, Decision One s counterclaim asserts claims purportedly arising out of prepetition contracts, and thus those claims are prepetition claims. Notwithstanding that Decision One was notified of RFC s bankruptcy filing, the deadline for filing proofs of claim, and the Plan and Confirmation Hearing, it appears Decision One failed to file a timely proof of claim preserving the claims it now asserts. Accordingly, those claims were discharged (see, e.g., Confirmation Order 42), and Decision One is enjoined from pursuing the counterclaim (see, e.g., Plan Art. IX(I)). See also Plan Art. IX(I)) ( Any person injured by any willful violation of this injunction shall be entitled to recover actual damages, including costs and attorneys fees and, in appropriate circumstances, may recover punitive damages. ). As we stated on the call, we therefore request that Decision One withdraw its counterclaim immediately. If Decision One is unwilling to do so, we plan to file a motion to enforce the Plan Injunction in the Bankruptcy Court, and we request that Decision One consent to an extension of RFC s time to answer or otherwise respond to the Counterclaim in front of Judge Nelson, until Judge Glenn has had an opportunity to rule on that motion. Please let us know if you have any questions or would like to discuss further. Best, Matt Matthew Scheck Associate Quinn Emanuel Urquhart & Sullivan, LLP 865 S. Figueroa Street, 10th Floor Los Angeles, CA 90017 213-443-3190 Direct 213-443-3000 Main Office Number 213-443-3100 Fax matthewscheck@quinnemanuel.com www.quinnemanuel.com NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. 1
12-12020-mg Doc 8948-4 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit D Pg 1 of 2 EXHIBIT D
12-12020-mg Doc 8948-4 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit D Pg 2 of 2 Matthew Scheck From: Sent: To: Cc: Subject: Matthew Scheck Thursday, July 16, 2015 11:39 AM Tessa Somers Isaac Nesser PHH Counterclaim Tessa, Further to your conversation with Isaac this morning, PHH s counterclaim asserts claims purportedly arising out of prepetition contracts, and thus those claims are prepetition claims. Notwithstanding that PHH was notified of RFC s bankruptcy filing, the deadline for filing proofs of claim, and the Plan and Confirmation Hearing, PHH only filed a limited proof of claim, and failed to file a proof of claim preserving the claims it now asserts in its counterclaim. Accordingly, those claims were discharged (see, e.g., Confirmation Order 42), and PHH is enjoined from pursuing the counterclaim (see, e.g., Plan Art. IX(I)). See also Plan Art. IX(I)) ( Any person injured by any willful violation of this injunction shall be entitled to recover actual damages, including costs and attorneys fees and, in appropriate circumstances, may recover punitive damages. ). If PHH is unwilling to do so, we plan to file a motion to enforce the Plan Injunction in the Bankruptcy Court, and we request that PHH consent to an extension of RFC s time to answer or otherwise respond to the Counterclaim in front of Judge Nelson, until Judge Glenn has had an opportunity to rule on that motion. Please let us know if you have any questions or would like to discuss further. Best, Matt Matthew Scheck Associate Quinn Emanuel Urquhart & Sullivan, LLP 865 S. Figueroa Street, 10th Floor Los Angeles, CA 90017 213-443-3190 Direct 213-443-3000 Main Office Number 213-443-3100 Fax matthewscheck@quinnemanuel.com www.quinnemanuel.com NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. 1
12-12020-mg Doc 8948-5 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit E Pg 1 of 2 EXHIBIT E
12-12020-mg Doc 8948-5 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit E Pg 2 of 2 Matthew Scheck From: Sent: To: Cc: Subject: Matthew Scheck Friday, July 17, 2015 9:50 AM tchris@aj-law.com; garth@aj-law.com; lindsay@aj-law.com; jrice@nmichlaw.com Isaac Nesser Rescap -- Honor Bank Counterclaim Chris, I tried calling you to discuss the counterclaim you filed yesterday on behalf of Honor Bank against the Rescap Liquidating Trust, but understand that you are away. Because the issue is significant and time sensitive, I thought it best to follow up by email. In short, the counterclaim asserts claims that were discharged in Rescap's bankruptcy plan, and which are now pending in violation of the bankruptcy plan s express injunction against such claims. Specifically, the counterclaim asserts claims purportedly arising out of pre-petition contracts, which are thus pre-petition claims that cannot be asserted unless Honor Bank preserved them by filing a timely proof of claim. It appears that Honor Bank did not file such a proof of claim despite having received notice of the deadline for filing proofs of claim, and notice of the Plan and Confirmation Hearing. Accordingly, the claims were discharged (see, e.g., Confirmation Order 42), and Honor Bank is enjoined from pursuing the counterclaim (see, e.g., Plan Art. IX(I)). See also Plan Art. IX(I)) ( Any person injured by any willful violation of this injunction shall be entitled to recover actual damages, including costs and attorneys fees and, in appropriate circumstances, may recover punitive damages. ). We therefore request that Honor Bank withdraw its counterclaim immediately. If Honor Bank is unwilling to do so, we plan to file a motion to enforce the Plan Injunction in the Bankruptcy Court, and we request that Honor Bank consent to an extension of RFC s time to answer or otherwise respond to the Counterclaim in front of Judge Nelson, until Judge Glenn has had an opportunity to rule on that motion. Please let us know if you have any questions or would like to discuss further. If we are not able to resolve this issue promptly, we will plan to add it on Monday afternoon to the agenda for next week's hearing before Judge Nelson. Best, Matt Matthew Scheck Associate Quinn Emanuel Urquhart & Sullivan, LLP 865 S. Figueroa Street, 10th Floor Los Angeles, CA 90017 213-443-3190 Direct 213-443-3000 Main Office Number 213-443-3100 Fax matthewscheck@quinnemanuel.com www.quinnemanuel.com NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. 1
12-12020-mg Doc 8948-6 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit F Pg 1 of 2 EXHIBIT F
12-12020-mg Doc 8948-6 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit F Pg 2 of 2 Matthew Scheck From: Sent: To: Cc: Subject: Matthew Scheck Monday, July 20, 2015 12:47 PM 'jjenkins@jmjenkinslaw.com' Isaac Nesser; Matthew Scheck Rescap--Sierra Pacific Counterclaim Jonathan, I emailed you on Friday to try to setup a call to discuss Sierra Pacific s counterclaim against RFC and the Rescap Liquidating Trust, and Isaac tried to call you today as well. Because the issue is significant and time sensitive, I thought it best to follow up by email. In short, as RFC and the Trust set forth in their answer to the counterclaim (see Fourth Aff. Def.), Sierra Pacific s counterclaim asserts claims that were discharged in Rescap's bankruptcy plan, and which are now pending in violation of the bankruptcy plan s express injunction against such claims. Specifically, the counterclaim asserts claims purportedly arising out of pre-petition contracts, which are thus pre-petition claims that cannot be asserted unless Sierra Pacific preserved them by filing a timely proof of claim. It appears that Sierra Pacific did not file such a proof of claim despite having received notice of the deadline for filing proofs of claim, and notice of the Plan and Confirmation Hearing. Accordingly, the claims were discharged (see, e.g., Confirmation Order 42), and Sierra Pacific is enjoined from pursuing the counterclaim (see, e.g., Plan Art. IX(I)). See also Plan Art. IX(I)) ( Any person injured by any willful violation of this injunction shall be entitled to recover actual damages, including costs and attorneys fees and, in appropriate circumstances, may recover punitive damages. ). We therefore request that Sierra Pacific withdraw its counterclaim immediately. If Sierra Pacific is unwilling to do so, we plan to file a motion to enforce the Plan Injunction in the Bankruptcy Court. Please let us know if you have any questions or would like to discuss further. Best, Matt Matthew Scheck Associate Quinn Emanuel Urquhart & Sullivan, LLP 865 S. Figueroa Street, 10th Floor Los Angeles, CA 90017 213-443-3190 Direct 213-443-3000 Main Office Number 213-443-3100 Fax matthewscheck@quinnemanuel.com www.quinnemanuel.com NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. 1
12-12020-mg Doc 8948-7 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit G Pg 1 of 6 EXHIBIT G
12-12020-mg Doc 8948-7 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit G Pg 2 of 6 1 1 2 3 4 5 6 7 8 9 10 11 12 13 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA --------------------------------------------------------------- In Re: RFC and RESCAP Liquidating Trust Litigation File No. 13-cv-3451 St. Paul, Minnesota Devitt Ceremonial Courtroom July 23, 2015 9:30 a.m. --------------------------------------------------------------- BEFORE: The Hon. SUSAN RICHARD NELSON, United States District Judge The Hon. HILDY BOWBEER, United States Magistrate Judge 14 15 16 STATUS CONFERENCE AND MOTIONS HEARING 17 18 19 20 21 22 23 24 25 Official Court Reporter: Heather Schuetz, RMR, CRR, CCP U.S. Courthouse, Ste. 146 316 North Robert Street St. Paul, Minnesota 55101 Heather_Schuetz@mnd.uscourts.gov Heather A. Schuetz, RMR, CRR, CCP (651) 848-1223 Heather_Schuetz@mnd.uscourts.gov
12-12020-mg Doc 8948-7 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit G Pg 3 of 6 78 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Mr. Jenkins' benefit, I don't know if he has already discussed this, but with his Codefendants, but I believe that the Wells Fargo Defendants had the same concern and we agreed on a stipulation with their counsel, Munger Tolles & Olson, that I believe they believe preserves their appellate rights. And so Mr. Jenkins may want to talk to them about the research that they've done on that issue. JUDGE NELSON: Great. Thanks. Anything else on this issue? (None indicated.) JUDGE NELSON: All right. We'll move ahead then to the response to certain of Defendants' counterclaims. MR. ISAAC NESSER: Your Honor, merely as a courtesy, we wanted to inform the Court there are four Defendants in these actions who have asserted counterclaims against the trust in their -- as part of their answer in these litigations. It is the trust's current view that those counterclaims are pending in violation of an injunction that was included in the bankruptcy plan issued by Judge Glenn. And the argument, in a sentence, is that the bankruptcy plan precludes -- discharges any liability in connection with certain contracts to which RFC was a party and the counterclaims that are now pending relate to issues that we believe were discharged in the bankruptcy. As a result of that, we are currently planning to Heather A. Schuetz, RMR, CRR, CCP (651) 848-1223 Heather_Schuetz@mnd.uscourts.gov
12-12020-mg Doc 8948-7 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit G Pg 4 of 6 79 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 file a motion with Judge Glenn in the Bankruptcy Court to enforce the injunction that is included in his order, which is to say that's included in the bankruptcy plan. We wanted to make Your Honors aware of that only because these are cases that are pending before Your Honor and so insofar as we're presenting issues relating to them in another court, we just thought you ought to be aware. JUDGE NELSON: Thank you. MR. ISAAC NESSER: Thank you. JUDGE NELSON: Any Defendant wish to respond to that? MR. MATTHEW JOHNSON: Matt Johnson, Williams & Connolly, on behalf of Decision One. Obviously, there's no motion pending before the Court. I understand Mr. Nesser's intention to provide a courtesy to the Court. Decision One has agreed to extend the deadline to answer or otherwise plead in this case until September 9th of 2015. So the issue really is -- will be in front of Judge Glenn if Plaintiffs choose to file a motion there. We think Plaintiffs' position lacks any merit whatsoever and defies commonsense and if Plaintiffs go ahead and bring their motion in front of Judge Glenn, we look forward to briefing the issue. JUDGE NELSON: Very good. Mr. Nesser. Heather A. Schuetz, RMR, CRR, CCP (651) 848-1223 Heather_Schuetz@mnd.uscourts.gov
12-12020-mg Doc 8948-7 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit G Pg 5 of 6 80 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. ISAAC NESSER: I hope that I've not defied commonsense in any respect, but, you know, we did not include, as part of the agenda, an issue that Mr. Johnson just raised but since he raised it, I thought I might address it in two sentences. And that is, of the four Defendants that are at issue with respect to this counterclaim issue, three of them filed their counterclaims in the last week or so. And the situation that arose was one in which we were going to have to simultaneously file motion in New York and brief a motion to dismiss before Your Honors on the same issue. We thought that that would be wasteful and duplicative and so we were able, thankfully, to reach agreements with the relevant Defendants to extend our response date on the counterclaims through to September 9. And that will permit us some time to present the issue to Judge Glenn but not only that will permit the Defendants here some time to assess our position and determine whether they will fully and finally be willing to adjourn our response date here until Judge Glenn actually rules on the motion in New York because it's unlikely that that will be resolved by August -- by September 9th. What I've discussed with the Defendants is, you know, we have resolved it for now. It doesn't need to be -- we're not seeking any relief during today's conference. But we will need to revisit it at next month's conference before Heather A. Schuetz, RMR, CRR, CCP (651) 848-1223 Heather_Schuetz@mnd.uscourts.gov
12-12020-mg Doc 8948-7 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit G Pg 6 of 6 81 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Your Honors in the event that we don't have a final agreement from these Defendants to adjourn our response date pending Judge Glenn's decision. Thank you. JUDGE NELSON: Okay. We'll address that at the next conference. Very good. All right. We will now -- I should say I will now turn it over to Judge Bowbeer -- and I sit here, but she'll entertain argument, oral argument on the RFC versus Impac issue. MAGISTRATE JUDGE BOWBEER: I believe the request for IDR came from Impac. So, I'll let you proceed. MR. ANTHONY ALDEN: Judge Bowbeer, do you want the IDR to be on the record or off the record? I just wasn't clear. I thought the normal procedure is for it to be off the record, but I just wanted to -- MAGISTRATE JUDGE BOWBEER: Yes, when we've done it by telephone conference, it's been off the record because there was -- yeah, because it's that informal. But I think here -- JUDGE NELSON: Is there an opposition to having it on the record? MR. ANTHONY ALDEN: No, I just wanted to -- MAGISTRATE JUDGE BOWBEER: No, and I appreciate the request for clarification. I think as long as we're here and we've got a court reporter, we'll proceed. But you're correct Heather A. Schuetz, RMR, CRR, CCP (651) 848-1223 Heather_Schuetz@mnd.uscourts.gov
12-12020-mg Doc 8948-8 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit H Pg 1 of 3 EXHIBIT H
12-12020-mg Doc 8948-8 RENEWAL Filed OF 07/31/15 REGISTRATION Entered 07/31/15 12:53:48 E-FILED Exhibit H Pg 2 of 3 Jul 19, 2012 Corporation Division www.filinginoregon.com OREGON SECRETARY OF STATE REGISTRY NUMBER 9874397 REGISTRATION DATE 08/20/2002 BUSINESS NAME 1ST CHOICE MORTGAGE OF OREGON BUSINESS ACTIVITY MORTGAGE LENDING MAILING ADDRESS 50 IRON POINT CIRCLE STE #200 FOLSOM CA 95630 USA TYPE ASSUMED BUSINESS NAME PRIMARY PLACE OF BUSINESS 250 BROADALBIN ST SW STE 2-B ALBANY OR 97321 USA JURISDICTION OREGON COUNTIES AUTHORIZED REPRESENTATIVE BAKER, BENTON, CLACKAMAS, CLATSOP, COLUMBIA, COOS, CROOK, CURRY, DESCHUTES, DOUGLAS, GILLIAM, GRANT, HARNEY, HOOD RIVER, JACKSON, JEFFERSON, JOSEPHINE, KLAMATH, LAKE, LANE, LINCOLN, LINN, MALHEUR, MARION, MORROW, MULTNOMAH, POLK, SHERMAN, TILLAMOOK, UMATILLA, UNION, WALLOWA, WASCO, WASHINGTON, WHEELER, YAMHILL JAMES E COFFRINI 50 IRON POINT CIRCLE STE #200 FOLSOM CA 95630 USA REGISTRANT 53190782 - SIERRA PACIFIC MORTGAGE COMPANY, INC. SIGNER JAMES COFFRINI Page 1 of 2
12-12020-mg Doc 8948-8 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit H By my signature, I declare as an authorized authority, that this filing has been examined by me and is, to the best of my Pg 3 of 3 knowledge and belief, true, correct, and complete. Making false statements in this document is against the law and may be penalized by fines, imprisonment, or both. By typing my name in the electronic signature field, I am agreeing to conduct business electronically with the State of Oregon. I understand that transactions and/or signatures in records may not be denied legal effect solely because they are conducted, executed, or prepared in electronic form and that if a law requires a record or signature to be in writing, an electronic record or signature satisfies that requirement. ELECTRONIC SIGNATURE TITLE JAMES COFFRINI AUTHORIZED REPRESENTATIVE DATE SIGNED 2012-07-18 Page 2 of 2
12-12020-mg Doc 8948-9 Filed 07/31/15 Entered 07/31/15 12:53:48 Exhibit I Pg 1 of 2 EXHIBIT I
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